Today, on 25 January 2022, a new set of personal special economic and other restrictive measures (sanctions) became effective (“Decisions“)[1]. The Decisions impose extensive sanctions restrictions, including asset freezes, restriction on the exit of capital from Ukraine, suspension of the performance of economic and financial obligations, a ban on trade operations, prohibition of participation in privatization and leasing of state property, cancellation of visas and licenses, entry bans, etc., upon the following legal entities and individuals:

  • Russian companies involved in transport design and construction, industrial and energy infrastructure, geodetic and cartographic works, and insurance-related business (i.e., LENMORNIIPROEKT JSC, Lenpromtransproekt JSC, Insurance Business Group JSC, Gas Industry Insurance Company JSC, Grand Service Express Transport Company JSC, Giproshakht OJSC, Russian Institute of Urban Planning and Investment Development “Giprogor” OJSC, ALARM911 Neva LLC, Geozemstroy LLC, Krymsetenergoproekt LLC, Research Institute of Diagnostics LLC, Research Institute of Perspective Urban Planning LLC, Nivad LLC, SIRIUS PROJECT LLC, Transproekt LLC, Tyus Management Company LLC, Transstroy Holding Company LLC, Federal Target Program “Modernization of the Russian Transport System”)
  • Austrian architectural bureau COOP HIMMELB(L)AU Wolf D. Prix & Partner ZT GmbH and its associated persons (legal entities and individuals) for the design of an opera and ballet theatre in Sevastopol (the Crimea) in violation of Ukrainian law.
  • Cypriot company BISCONE LIMITED
  • Russian federal security companies and firms providing tourism and cultural services (i.e., Federal State Enterprise “Departmental security of railway transport of the Russian Federation,” Federal State Enterprise “Office of security department of the Ministry of Transport of the Russian Federation,” State Autonomous Institution of the City of Sevastopol “Center of Tourism Development,” Fund for Social and Cultural Projects “National Cultural Heritage,” Autonomous NGO for the Promotion of Concert Activities “Russian Seasons”)
  • Judges and law enforcement officials in the temporarily occupied Crimea and the Russian Federation

The full lists of the legal entities and individuals subject to sanctions are set forth in the annexes to the Decisions.
 
Any counterparty dealing with entities or individuals on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.

[1] Presidential Decree No. 19/2022 dated 21 January 2022 “On the Decision of the National Security and Defense Council dated 30 December 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 25 January 2022; Presidential Decree No. 20/2022 dated 21 January 2022 “On the Decision of the National Security and Defense Council dated 30 December 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 25 January 2022; Presidential Decree No. 21/2022 dated 21 January 2022 “On the Decision of the National Security and Defense Council dated 30 December 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 25 January 2022; Presidential Decree No. 22/2022 dated 21 January 2022 “On the Decision of the National Security and Defense Council dated 30 December 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 25 January 2022.

Author

Hanna Shtepa is a Counsel of the Kyiv office of Baker McKenzie specializing in economic sanctions, export controls, international supplies of goods and services, public procurement regulations. She has significant experience on advising clients on supplies to Ukraine, participation in Ukrainian public procurement tenders, special regime of trade and business activities in the Crimea and uncontrolled territories in the East of Ukraine, Ukrainian sanctions restrictions against Russia. Hanna is experienced in drafting and negotiation of supply contracts, including procurement contracts for public needs, trade compliance policies and trade finance agreements. Hanna held a number of training and presentations for Ukrainian banks and corporate clients on compliance with Ukrainian sanctions and special trade regimes with the Crimea and uncontrolled territories in the East of Ukraine. She is one of the contributors to Baker McKenzie sanctions blog.